EMP Implementation Support: turning the Environment Management Plan into work that happens on site.

The EMP is the part of the environmental assessment that commits a project to specific mitigation, monitoring, institutional arrangements and budgets for its environmental effects. It is what the appraisal authority relies on when granting clearance, and its commitments are carried into the clearance as conditions.

In itself it is a technical document, but its commitments become binding through the conditions of the Environment Clearance, which are enforceable under the Environment (Protection) Act 1986. In practice, a commitment made in the EMP to secure a clearance should be treated as an obligation from the day the clearance is granted.

The proponent, through the project and operations teams and the environment management cell the EMP provides for. A consultant can design procedures, train the team, monitor and review, but the statutory responsibility for what happens on site rests with the occupier.

It is the in-house function the EMP commits to: responsible for running the monitoring programme, maintaining records, operating and supervising pollution control facilities, handling waste documentation and preparing compliance reporting. Its existence, staffing and qualifications are themselves often a condition, and they are checked.

On the committed extent, the species mix and the survival rate, evidenced by a plantation record and periodic enumeration with dates and locations. Planting without enumeration is the most common shortfall, because the site can show trees but cannot show that the committed number survives at the committed density.

The EIA consultant assesses impacts and writes the plan; implementation support works with the project team after the clearance to make the plan operational and evidenced. The two are sequential, and a plan written without regard to how it will be implemented is exactly what produces post-clearance difficulty.

Whether the committed facilities exist and are functioning, whether monitoring has been done at the committed frequency by a recognised laboratory, whether waste has gone to authorised handlers with documentation, and whether the budget committed has been spent. The inspection is largely a documentary exercise conducted on site.

The plan can be updated operationally, but where a change affects a commitment carried into the clearance conditions, the change belongs in an amendment application to the granting authority. Improving on a commitment is unproblematic; quietly reducing one is not.